Transportation Institutional Issues: The Post Yucca Years

TRANSPORTATION RISK MANAGEMENT PROGRAM

security risk assessment appeared to be organized appropriately, and that, once available, results of the risk assessment should be merged into an integrated all-hazards risk management approach. The Board again highlighted the need to make risk assessment and risk communication iterative processes conducted with stakeholders (NWTRB 2005b, p. 8). In addition to the NWTRB, the NAS also addressed risk management. In Going the Distance , the NAS found that, while the health and safety risks of transporting spent fuel are low, the risks perceived by society presented a challenge to the success of the national transportation program. The NAS recommended that the transportation program act early to develop mechanisms for gathering diverse, quality information on perceived risks and risk management. Specifically, the committee recommended the establishment of a “ transportation risk advisory group that is explicitly designed to provide advice on characterizing, communicating, and mitigating the social, security, and health and safety risks that arise from the transportation of spent fuel and high-level waste to a federal repository or interim storage” (emphasis in original) (NAS 2006, p. 181). OCRWM has defined a risk as “an uncertain event or condition that, if it occurs, affects a project or program’s objectives, including cost, schedule, or overall scope of work” (DOE 2007a, p. 19). A risk is comprised of the likelihood of the risk to occur, referred to as probability, and the consequences if the event does occur, referred to as impacts. OCRWM defined risk management as “a process of integrating scientific information and societal values into a decisional framework” (DOE 1995h, p. 1). Risk management is required for DOE projects and programs under Department of Energy Order 413.3 and 413.301, which describe the department’s approach to risk management. According to DOE Directive 413.3, “Risk Management is an essential element of every project. The DOE risk management approach must be analytical, forward looking, structured, informative, and continuous” (DOE 2006a, p. 32). OCRWM has issued several documents that touch on the office’s approach to managing risk as it relates to the national transportation program. In the 1994 “Developing the Transportation System,”OCRWM acknowledged that a transportation risk management programwould need to be developed to“aid decision making in transportation system design and operations, and to limit environmental, safety, and health impacts” (DOE 1994c, p. 5-6). Through this program, OCRWMwould identify the risks associated with the transportation of spent fuel and high-level waste and implement appropriate mitigative measures to address these risks. OCRWM envisioned that this process would be conducted in open consultation with stakeholders, and would include strategies for risk communication. OCRWM planned to issue a draft transportation risk management strategy in 1994. In OCRWM’s 1995 Transportation Contingency Plan for Limited Capacity Shipment , the program reiterated that a risk management program was currently under development. Stakeholders had requested that a risk management program, including capabilities for risk communication, risk assessment, risk reduction, and risk monitoring, be developed well in advance of the start of shipment

The NWTRB repeatedly urged OCRWM to improve its understanding of transportation risk and to develop a full- fledged program dedicated to managing that risk. Because transportation of high-level waste and spent fuel is perceived by the public as risky, the NWTRB encouraged OCRWM to address both actual and perceived risks, and to involve stakeholders extensively in the identification and analysis of risks. This recommendation has been echoed by the NAS. OCRWM has addressed its approach to risk management in several transportation-related documents, most notably the “Transportation Risk Management Approach, Preliminary Draft” issued in 1995. While this document included plans for a comprehensive risk management program, none was ever developed. The NWTRB has consistently highlighted transportation risk management as an area of public concern that warranted greater attention from OCRWM. The Board repeatedly stated that although the actual risks associated with transporting spent fuel and high- level waste are low, the perceived risks by the public could present an obstacle for OCRWM in developing and carrying out a national transportation program for highly-radioactive material. The Board therefore urged OCRWM to take measures to enhance public confidence in transportation of spent fuel (NWTRB 1998, p. 14). In 1990, in its First Report to the U.S. Congress and the U.S. Secretary of Energy, the NWTRB identified “Risk Assessment and Management” in the transportation program as an issue of concern. The Board recommended that OCRWM initiate a system safety program that utilized a Management Oversight Risk Tree and RADTRAN, a model used to assess the risks of transporting radioactive materials under both incident free and accident conditions (NWTRB 1990a, p. 26). The Board’s Third Report to the U.S. Congress and the U.S. Secretary of Energy concluded that “[t]he transportation of high-level radioactive waste is, and is perceived by the public to be, an activity of high safety concern” (NWTRB 1991, p. 20). The Board encouraged OCRWM to address these concerns by taking steps that would improve overall safety and enhance public confidence. In 1997, the Board held a meeting on the waste management system, with analyses of the risks associated with transporting spent fuel being one of the three topics discussed. Afterwards, in its 1997 Findings and Recommendations, the NWTRB again concluded that the risks associated with transporting spent fuel are and will continue to be low. They recommended that in order to maintain a good safety record, a heightened safety programmay be needed in the civilian nuclear waste management program (NWTRB 1998, p. 14). The Board’s May 2005 Report to Congress and the Secretary of Energy revisited the topic of risk management. One of the key findings in this report was that OCRWM had made substantial progress in the area of transportation planning. In the report, the Board concluded that OCRWM’s approach to transportation

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